Cyprus - GAAR: Capturing Non-Genuine Transactions

Offshore Tax with HTJ.tax · Oct 16, 2025 · 2m

In this episode, we explore the General Anti-Abuse Rule (GAAR) introduced in Cyprus under the EU’s Anti-Tax Avoidance Directive (ATAD). The GAAR serves as a broad safeguard against aggressive tax planning that may fall outside specific anti-avoidance rules like transfer pricing, CFC, or interest limitation provisions.We break down how Cyprus applies the GAAR to non-genuine arrangements, what counts as “economic reality,” and how the rule fits into the broader international move toward substance-based taxation.⚖️ The Rule in FocusUnder the Cyprus GAAR, any arrangement or series of arrangements…